As mentioned earlier, we have received no specific complaints by consumers since the beginning of 1991 about the use of the Rule of 78s in prepayments and very few complaints about prepayment penalties of any sort.

While the REITs that invest primarily in commercial mortgage-backed securities (CMBS) and direct commercial mortgages are less impacted by prepayments due to higher prepayment penalties on commercial mortgages, the investing public has tended to group all mortgage REITs together, according to Dubrowski.

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